ML20052H454
| ML20052H454 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/19/1982 |
| From: | Hinson C, Danni Smith, Wing J NRC |
| To: | |
| Shared Package | |
| ML20052H450 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8205210076 | |
| Download: ML20052H454 (16) | |
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forth in NUREG-0313, Revision 1, for ASME Code Class I and II reactor coolant pressure bounda ry piping.
(2) The commitment to inspect portions of the reactor recirculation system and transition
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welds that have been classified as "non-conforming" per NUREG-0313, Revision 1, has been conditioned by LILCO to be limited "to the extent practicable" due to physical interferences in some locations.
NUREG-0313 does not specifically allow for such deviations. Also, LILCO has failed to identify specifically the number, location, and detailed justification for these deviations.
Further, LILCO's objection to the
" service sensitive" classification of recirculation riser lines and inlet lines at the safe-end curves demonstrates a failure to comply with the requirements of NUREG-0313.
Q.
Do all parts of the three contentions address the same concern?
14.
No.
SC Contention 24(b) concerns NUREG-0619 while all other
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t parts of these contentions concern stainless steel piping and their weldments as covered by Reg. Guide 1.31, " Control of Ferrite Content in Stainless Steel Weld Metal," Reg. Guide 1.44, " Control of the Use of Sensitized Stainless Steel," and NUREG-0313, Rev.1; "Techn,ical Report on l'aterial Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping."
Q.
What is the NRC Staff's position concerning SC Contention 24(b) which alleges that Shoreham has not installed a flow controller as recommended in NUREG-0619?
A.
LILC0 has informed the NRC Staff that two low flow control valves have been installed in parallel with split range control. The up% ts k ofr rodel G\\og a
split range control enables con, trol to below 0.1% of rated flow /g tendih3 '~'^
' -it :f the range of desired control which has been cat:-fi" t-B20521CKy76 820519 PDR ADOCK 05000322 T
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described as 0.5%g The Applicant will monitor temperature variations during start up to evaluate the need for additional controls, and has stated he will establish additional controls / procedures if necessary.
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Therefore, SC Contention 24(b) is invalid.
Q.
What is the NRC Staff's position with respect to the con-formance,of_the Sho,reham design to the requirements of NUREG-0313? [SC 24(a)andSOC19(d)(1)and(2)].
A.
NUREG-0313, Rev. I outlines several methods to minimize crack susceptibility.
It specifically allows for several materials and processing alternatives with inservice inspection requirements related to the materials and processing variables used in construction.
The Applicant has followid the requirements of NUREG-0313, Rev. -1, as to mal.erial selection and processing.
LILC0 has, for practical reasons, asked for relief as permitted hv 10 C.F.R. 50.55a(g)(6)(i) from some of the inservice inspection requirements specified in the NUREG.
The intent of NUREG-0313, Rev. 1 is to prevent,the maintenance problem of leaks caused by intergranular stress corrosion c' racking '
(IGSCC) in class 1, 2, and 3 stainless steel piping systeins. These leaks due to IGSCC are not regarded as a significant concern to public health and safety because the inherent fracture toughness of the stainless steels used will prevent rapidly propagating pipe failure, and the leaks which occur will remain small for a considerable period of time.
The monitoring of fluid accumulation from these type leaks has served as the major detection method for IGSCC.
IGSCC is a system problem in those stainless steel piping systems which are susceptable to this form of corrosion; that is, it will not be localized to one weld joint, but will occur in several t
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.. forth in NUREG-0313, Revision 1, for ASME Code Class I and II reactor coolant pressure bounda ry piping.
(2) The commitment to inspect portions of the reactor recirculation system and transition welds that have been classified as "non-conforming" per NUREG-0313, Revision 1, has been conditioned by LILCO to be limited "to the extent practicable" due to physical interferences in some locations.
NUREG-0313 does not specifically allow for such deviations. Also, LILCO has failed to identify specifically the number, location, and detailed justification for these deviations.
Further, LILCO's objection to the
" service sensitive" classification of recirculation riser lines and inlet lines at the safe-end curves demonstrates a failure to comply with the requirements of NUREG-0313.
Q.
Do all parts of the three contentions address the same concern?
SA.
No.
SC Contention 24(b) concerns NUREG-0619 while all other parts of these contentions concern stainless steel piping and their weldments as covered by Reg. Guide 1.31, " Control of Ferrite Content in Stainless Steel Weld Metal," Reg. Guide 1.44, " Control of the Use of Sensitized Stainle3s Steel," and NUREG-0313, Rev.1, " Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping."
Q.
What is the NRC Staff's position concerning SC Contention 24(b) which alleges that Shoreham has not installed a flow controller as recommended in NUREG-06197 A.
LILC0 has informed the NRC Staff that two low flow control valves have been installed in parallel with split range control. The split range control enables control to below 0.1% of rated flow up to 15% of rated flow, expanding the range of desired control which has been r
l
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described as 0.5% to 10%.
The Applicant will monitor temperature variations during start up to evaluate the need for additional controls, and has stated he will establish additional controls / procedures if necessary.
Therefore, SC Contention 24(b) is invalid.
^
Q.
What is the NRC Staff's position with respect to the con-I formance of_ the Shoreham design to the requirements of NUREG-0313? [SC 24(a) and 50C 19(d)(1) and (2)].
A.
NUREG-0313, Rev.1 outlines several methods to minimize crack susceptibility.
It specifically allows for several materials and processing alternat.ives with inservice inspection requirements related to the materials and processing variables used in construction.
The Appli. cant has followed the requirements of.NUREG-0313, Rev.1, as to material selection and processing.
LILCO has, for practical reasons, asked ~for relief as permitted hv 10 C.F.R. 50.55a(g)(6)(i) from some of the inservice inspection requirements specified in the NUREG.
The intent of NUREG-0313, Rev.1 is to prevent,the maintenance problem of leaks caused by intergranular stress corrosion cracking '
(ISSCC) in class 1, 2, and 3 stainless steel piping systems.
These leaks due to IGSCC are not regarded as a significant concern to public health and safety because the inherent fracture toughness of the stainless steels used will prevent rapidly propagating pipe failure, and the leaks which occur will remain small for a considerable period of time.
The monitoring of fluid accumulation # rom these type leaks has served as the major detection method for IGSCC.
IGSCC is a system problem in those stainless steel piping systems which are susceptable to this form of corrosion; that is, it will not be localized to one weld joint, but will occur in several 9
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have adequate space to add, test, and remove charcoal and HEPA filters.
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rn";.O!r _. w.; t;' 4 ~; H - ::. rm : C;2 4: ~ ::utly-In areas of the plant where permanent shielding is not
_:: W practicable, steel supports and large access ways have been provided for Portable shielding has been provided for
- tihe use,of portab)e shielding.
f refueling and inspection operations to minimize the dose accumu ated These plant and equipment layout provisions are during these periods.
consistent with the guidance of Regulatory Guide 8.8, Rev. 3.
To address Subpart (vi, have the condensers at Shoreham been Q.
optimally designed to minimize radiation exposure during maintenance by utilizing the minimum number of shell connections?
t A.
(CSH) This subpart is concerned with reducing maintenance exposure by minimizing the number of steam inlet connections (referred to as shell connections in the contention) to the main condenser at Use of a condenser inlet pipe configuration having fewer pipe Shoreham.
connections than the Shoreham design could theoretically result in a small reduction in the amount of radioactive material (commonly referred to as." crud") on the condenser tube surfaces.
The main condensers at Shoreham are of a standard design and have been designed in accordance with guidance contained in the document Standard for Steam Surface Condensers.1/.These condense the turbine building below the main turbine and moisture separator Their function is to condens primary steam coming from the
/
reheators.
Standards for Steam Surface Condensers, Seventh Edition, Heat 1/
Exchange Institute, 1978.
. indicated by its electrical conductivity.
The limits for the con-ductivity in the condensate system water have been established in accordance with the recommendations in Table 2 of Regulatory Guide 1.56, Revision 1.
The conductivity of the feedwater is continuously monitored to ensure that its limits are not exceeded.
Apnropriate corrective pctions will be,taken when the limit of conductivity in the feedwater is exceeded, consistent with the recommendations in Table 2 of Regulatory Guide 1.56, Revision 1.
l An oxygen control program to reduce material corrosion rates in the l
primary coolant syst' ems was recommended by the General Electric Company to all boiling water reactor operators, in the report, "BWR Coolant 0xygen Control", NEDD-23631 (June 1977).
We are of the opinion that an oxyge$ control program will reduce materials corrosion rates and radiation buildup, including iron-cobalt buildup, in the primary system, indh. dea thd W wW bele.,
The Shoreham Nuclear Power Station has r"tt:d t; an oxygen control l
program to minimize iron-cobalt buildup in the primary ' system.,
In conclusion, the Shoreham Nuclear Power Station has developed l
procedures to limit iron-cobalt buildup in the primary system through the i
s.sL Reactor Water Cleanup Systemgthe Condensate Demineralizer System, r d =
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p ;;.;.
Shoreham has committed to implementing these L aMMich 3 hpuce+ ha4 indieded ed W *d\\ huf.,
procedures when the plant is in operation.
Implementation of these water o.m o.nd Trogro-m ogtm chemistry control procedures will provide assurance that occupational togo \\
radiation exposure will be'kept.as low as is reasonably achievable.
YY Q..
Addressing Subpart (ii) of Part (b), what are LILCO's procedures for monitoring and controlling individual and plant total annual occuaptional radiation doses? Are invidivual doses permitted to
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exceed three rems per quarter and five rems per year only on an emergency basis (which requires special management approval)?
A.
(CSH)
Th'e Applicant intends to maintain occupational radiation exposures at Shoreham as low as is reasonably achievable.
This policy applies to total man-rems accumulated by all personnel, as well as to individual exposures.
Each individual receives sufficient trainir.g so 4
that they are capable of carrying out their responsibility for main-taining their owr exposure as low as is reasonably achievable.
In addition, it is the responsibility of the Health Physics (HP) ' Staff to take positive steps 'to-reduce personnel exposures such that maximum individual radiation dose is always below the limits of 10 C.F.R. Part 20
" Standards for Protection Against Radiation" and the total in-plant dose is maintained ALARA.
The maximum allowable individual dose limit specified by 10 C.F.R. Part 20 is 1.25 rems per quarter ud '* c rz:
- n. 4. (an individuai may receive up to three rems per quarter cs long as he does not exc,eed the 5(N-1,8) rems limit).
All personnel who enter a Controlled Access Area at Shoreham are required to wear personnel monitoring devices at all times.
Pocket dosimeters are read and the dose recorded at least once during the working day.
Personnel TLD badges or film badges are processed monthly, or more frequently if significant exposures are expected:
Permanent lifetime, annual, and quarterly dose records are kept for all personnel.
Current exposure data is recorded on Form AEC-5, " Current Occupational External Radiation Exposure" or the equivalent.
The employees' prior radiation exposure history is recorded on Form AEC-4,-
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9 6-.
, have adequate space to add, test, and remove charcoal and HEPA filters.
In areas of the plant where permanent shieldino is not practicable, steel supports and large access vays have been provided for the use of portable shielding.
Portable shielding has been provided for a
refueling and inspection operations to minimize the dose accunulated during these periods.
These plant and equipment layout provisions are consistent with the guidance of Regulatory Guide 8.8, Rev. 3.
Q.
To address Subpart (vi, have the condensers at Shoreham been optimally designed to minimize radiation exposure during maintenance by utilizing the minimum nunber of shell connections?
A.
(CSH) This subpart is concerned with reducing maintenance exposure by minimizing the number of steam inlet connections (referred to as shell connections in the contention) to the main condenser at Shoreham.
Use of a condenser inlet pipe configuration having fewer pipe corections than the Shoreham design could theoretically result in a small reduction in the amount of radioactive material (commonly referred to as." crud") on the condenser tube surfaces.,
The main condensers at Shoreham are of a standard design and have been designed in accordance with guidance contained in the document Standard for Steam Surface Condensers.M.These condensers are located in the turbine building below the main turbine and moisture separator reheators.
Their function is to condense primary steam coming from the l
-1/
Standards for Steam Surface Condensers, Seventh Edition, Heat Exchange Institute, 1978.
a e,
indicated by its electrical conductivity.
The limits for the conductivity in the condensate system water have been established in accordance with the recommendations in Table 2 of Regulatory Guide 1.56, Revision 1.
The conductivity of the feedwater is continuously monitored to ensure that its limits are not exceeded. Appropriate corrective actions will be taken when
.the li,mit of conductivi.ty in the feedwater is exceeded, consisten.t with the recommendations in Table 2 of Regulatory Guide 1.56, Revision 1.
Any oxygen control program to reduce material corrosion rates in the primary coolant systems was recommended by the General Electric Company to all boiling water reactor operators, in the report. "BWR Coolant Oxygen Control", NED0-23631 (June 1977).
We are of the opinion that an oxygen control program will reduce materials corrosion rates and radiation buildup, inclu' ding iron-cobalt buildup, in the primary system.
The Shoreham Nuclear Power Station has indicated that it will have an oxygen control program to minimize iron-cobalt buildup in the primary system.
In conclusion, the Shoreham Nuclear Power Station has developed procedures to limit iron-cobalt buildup in the primary system through the Reactor Water Cleanup System and the Condensate Demineralizer System.
d Shoreham has committed to implementinj these procedures when the plant is.
in operation.
In addition, Applicant has indicated that it will have an oxygen control program.
Implementation of these water chemistry control procedures and program will provide assurance that occupational radiation exposure will be kept as low as is reasonably achievable.
~
Q.
Addressing Subpart (ii) of Part (b), what are LILCO's f
procedures for monitoring and controlling individual and plant total annual occupational radiation doses? Are individual doses permitted to
exceed three rems per quarter and five rems per year only on an emergency basis (which requires special management approval)?
A.
(CSH)
Th'e Applicant intends to maintain occupational radiation exposures at Shoreham as low as is reasonably achievable.
This policy applies to total man-rems accumulated by all parsonnel, as well as to individual exposures.
Each individual receives sufficient training so that they are capable of carrying out their responsibility for main-taining their own exposure as low as is reasonably achievable.
In addition, it is the responsibility of the Health Physics (HP) ' Staff to take positive steps 'to-reduce personnel exposures such that maximum individual radiation dose is always below the limits of 10 C.F.R. Part 20
" Standards-for Protection Against Radiation" and the total in-plant dose is mairitained ALARA.
The maximum allowable individual dose limit specified by 10 C.F.R. Part 20 is 1.25 rems per quarter (an individual.
may receive up to three rems per quarter as long as he does not exceed the 5(N-18) rems limit).
All personnel who enter a Controlled Access Area at Shoreham are required to wear personnel monitoring devices at all times.
Socket dosimeters are read and the dose recorded at least once during the working day.
Personnel TLD badges or film badges are processed monthly, or more frequently if significant exposures are expected:
Permanent lifetime, annual, and quarterly dose records are kept for all personnel.
Current exposure data is recorded on Form AEC-5, " Current Occupatiorial External Radiation Exposure" or the equivalent.
The employees' prior radiation exposure history is recorded on Form AEC-4,
a
'O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
LONG ISLAND LIGHTING COMPANY Docket No. 50-322
)
(OL)
(ShorehamNuclearPowerStation,
)
Unit 1)
)
8 v-CERTIFICATE OF SERVICE I hereby certify that copies of C00RECTIONS AND ADD'NS TO THE TESTIMONY OF DAVID E. SMITH ON' CONTENTIONS SC 24/ SOC 19(c), 19t, AND THE TESTIMONY OF CHARLES S. HINSON AND JAMES WING ON CONTENTION SC 26 in the above-captioned proceeding'have been served on the following by deposit in the
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United States mail, first class, or as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 19th day of May, 1982. -
Lawrence Brenner, Esq.*
Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, NY 10016 Washington, D.C.
20555 Dr. James L. Carpenter
- Administrative Judge Howard L. Blau, Esq.
Atoinic Safety and Licensing Board 217 Newbridge Road U.S. Nuclear Regulatory Commission Hicksville, NY 11801 Washington, DC 20555 Dr. Peter A. Morris
- W. Taylor Reveley III, Esq.
Administrative Judge Hunton & Williams Atomic Safety and Licensing Board P.O. Box 1535 U.S. Nuclear Regulatory Commission Richmond, VA 23212 Washington, DC 20555 Matthew J. Kelly, Esq.
Staff Counsel New York Public Service Commission 3 Rockefeller Plaza Albany, NY 12223 1
I Stephen B. Latham, Esq.
John F. Shea, III, Esq.
Herbert H. Brown, Esq.
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law Karla J. Letsche, Esq.
P.O. Box 398 Kirkpatrick, Lockhart, Hill, 33 West Second Street Christopher & Phillips Riverhead, NY 11901 1900 M Street, N.W.
8th Floor Washingtors, D.C.
20036 Atomic Safety and Licensing 4
Board Panel *_.
Docketing and Service Sect. ion
- r-U.S. Nuclear Regulatory Commission Office of the Secretary l
Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel
- U.S. Nuclear Regulatory Commission Washington, DC 20555 4
f Alb David A. RepKa 1
Counsel for NRC Staff
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O COURTESY COPY LIST Edward M. Barrett, Esq.
Mr. Jeff Smith General Counsel Shoreham Nuclear Power Station Long Island Lighting Company P.O. Box 618 250 Old County Road North Country Road Mineola, NY 11501 Wading River, NY 11792
.Mr. Brian McGaf.frey MHB Technical Associates..
Long Island Lighting Company 1723 Hamilton Avenue 175 East Old Country Road Suite K Hicksville, New York 11801 San Jose, CA 95125 Marc W. Goldsmith Hon. Peter Cohalsn Energy Research Group, Inc.
Suffolk County Executive 400-1 Totten Pond Road County Executive / Legislative Bldg Waltham, MA C2154 Veteran's Memorial Highway David H. Gilmartin, Esq.
Suffolk County Attorney Mr. Jay Dunkleberger County Executive / Legislative Bldg.
New York State Energy Office Vetergn's Memorial Highway Agency Building 2 Hauppauge, NY 11788 Empire State Plaza Albany, New York 12223 i
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